Stuff that occurs to me

All of my 'how to' posts are tagged here. The most popular posts are about blocking and private accounts on Twitter, also the science communication jobs list. None of the science or medical information I might post to this blog should be taken as medical advice (I'm not medically trained).

Think of this blog as a sort of nursery for my half-baked ideas hence 'stuff that occurs to me'.

Contact: @JoBrodie Email: jo DOT brodie AT gmail DOT com

Science in London: The 2018/19 scientific society talks in London blog post

Showing posts with label MHRA. Show all posts
Showing posts with label MHRA. Show all posts

Monday, 22 November 2021

My submission / response to the Consultation on the future regulation of medical devices in the United Kingdom

This follows on from my earlier blog post published Sun 21 Nov 2021
Open to all but closing 25 November 2021 - Consultation on the future regulation of medical devices in the United Kingdom, which has a full list of the questions. 

The consultation closes on 25 November 2021 and is open to everyone (patients, healthcare professionals, industry, academics, anyone). I've focused solely on the questions for members of the public in Chapter 17 and have replied as a member of the public. I previously worked on the CHI+MED project (which looked at ways of making medical devices safer) but not as a researcher. 

You might read my answers and think I've got something wrong or misunderstood something. If so, the best thing you can do is to fill in the consultation survey yourself as my answers can't be changed now (all submitted).

(1) You can read Chapter 17 "Questions for members of the general public" as a web page or download it as a PDF.

(2) You can give your views online here. 

(3) The full consultation (all chapters) is here. 

 

My responses
Here are my answers to the questions where a written response was possible. They were usually preceded by Yes / No / Not sure responses, which I've left out.

Q78.1 Do you think these products should be regulated under the UK medical devices regulations? (Yes/No/No Opinion/Don’t Know)

Q78.2 If you have answered ‘yes’ to question 78.1, which products should be regulated under the UK medical devices regulations (please select all those which apply) [see list in web page or PDF linked above in (1)]

Q78.3 Please provide your reasoning for your answers to questions 78.1-78.2 or any general comments on key considerations for the regulation of products without a medical purpose.

I hadn't realised liposuction tools weren't regulated and am surprised. I can only hope that the people who use them are regulated in some way, and have appropriate training in their use.

Some of the devices listed sound like they could be dangerous if used by poorly trained people but I expect that's out of the scope of your consultation. Genomic tests seem to be pretty harmless while being used but the advice given out alongside them is probably what's more concerning, so it's hard to separate the technical aspects from the way they're used to make decisions etc.

What about phone apps that offer vaguely medical support? I don't know if they're regulated, or if they should be - but probably outside your remit.

Q78.4 Do you think the classification rules for general medical devices and IVDs should be amended as above? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)  

Q78.5 Please provide your reasoning for your answer to question 78.4 or any general comments on the classification of medical devices (including ideas for other ways classification may need to change).

I'm between YES and DON'T KNOW as this seems a bit too technical for me, and I don't know what it is about some of these devices that makes them riskier (eg is the thing inherently risky or is it the way it's used - I've no idea how to do surgery so could probably do a lot of harm with a replacement joint that would be fine in competent hands).

What about devices that are used in quackery? For example bioresonance machines are Class IIa and don't seem to do anything useful. Alternative therapists who use them highlight the fact that they're Class IIa, which suggests they hope to benefit from the implication that they're 'approved' and 'a bit medical'. I'd suggest a new category - Class X (Entertainment) for those types of things ;)

Hearing aids that don't have lockable battery components should be in a higher risk class as button batteries can kill.

Q79.1 Do you think that health institutions should be required to meet certain requirements for ‘in house’ manufactured devices, such as those laid out above? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q79.2 If you have answered ‘yes’ to question 79.1, please choose which requirements should be met by health institutions (select all those which apply from the list below):
[see list in web page or PDF linked above in (1)]

Q79.3
Please provide your reasoning for your answers to questions 79.1 and 79.2, or any general comments on the rules that should apply to ‘in house’ manufacturing of medical devices.

I really don't know much about this, nor about the scale of manufacture (how often it occurs) or of modification (a minor tweak or a big change). It seems sensible that smart, technically-minded competent people - working within an appropriate healthcare framework - should be free to adapt things, within reason, to suit their needs without this being onerously regulated, but given that it's possible to do harm while intending to solve a problem I think records need to be kept as a bare minimum.

I think, as with 'official' devices, that near misses should be reported as well as actual incidents - and that these should also be fed back to the manufacturers. 


Q79.4 Do you think that medical device importers/distributors should meet additional requirements such as those outlined above? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)  

Q79.5 Please provide your reasoning for your answer to question 79.4 or any general comments on rules applying to importers/distributors of medical devices in the UK

I'm a bit surprised that this isn't already the case(?).

Q79.6 Do you think manufacturer should be required to assign UDI numbers to medical devices before they enter the UK market? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q79.7 What types/classes of medical devices should be included in the requirement for UDI storage (select only one)?
[see list in web page or PDF linked above in (1)]

Q79.8 Please provide your reasoning for your answers to questions 79.6-79.7 or any general comments on UDI requirements for medical devices.

I thought devices already had unique IDs, possibly given by the hospital or other care setting. It seems like a good idea but I suppose there's the possibility of giving people an awful lot of work in managing it. Q79.6 asks only about UDIs for devices entering the UK but it seems sensible to have this for devices made in the UK too, unless I am missing something about the scale of this (there are millions of medical devices!). Don't bandages have lot numbers? I'm doing regular LFTs and each one has its own QR code...

As part of modifications mentioned in 'Health Institutions' above is it possible that a component from one medical device might be transferred into another (if one breaks, using spare parts I mean)? I'm not sure how that would work with UDIs.

Q80.1 Do you think the UK medical devices regulations should include stricter requirements for claiming equivalence? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q80.2 If yes, should it be the requirements above or other? [multi-choice options of the above requirements plus other – please specify


Other: It seems like manufacturers should have to first prove that Device B *is* equivalent to Device A first, rather than claiming it.

Q80.3 Please provide your reasoning for your answers to question 80.1 and 80.2 and/or any general comments on rules that you think should apply to claiming equivalence to another medical device as set out above.

 This feels quite far beyond my knowledge of how this might play out in practice. I agree with the first three statements of Q80.2. I am not sure if the first statement is really just the same as my 'other' comment (might be). For the second statement (documentation) I think it would also be necessary to have access to some information about any underlying software too, as devices can differ in the ways they're programmed to do stuff, also if two similar devices have slightly different modes or states.

I don't know, for statement 4, where the cut-off should be, but agree that there should be a point at which manufacturers can't claim equivalence.

Q80.4 Do you think the UK medical devices regulations should introduce the requirement for an SSCP for medical devices? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q80.5 What types/classes of medical devices should require a SSCP (select all that apply)?

[I picked Other]: I think all medical devices (not medical spoons, bandages though) should have this.

Q80.6
Please provide your reasoning for your answers to questions 80.4-80.5 and/or any general comments on introducing a requirement for medical devices to have SSCPs.

This seems like a good idea. Definitely needs to be understandable by non-medical people. Seems useful to let many eyes look at stuff too. Again I would include information about any underlying software in this (I remember people trying to get hold of this sort of info for their implanted defibrillators and the companies were reluctant to share that info).

Any SSCP should be uploaded to and held by MHRA (with version control, should be possible to see earlier versions and what's changed). It should not be a link in case the document is moved / the URL is changed and no redirect set up.

Q82.1 Do you think manufacturers should be required to consult with patients when investigating device incidents? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q82.2 If you have answered ‘yes’ to question 82.1, how do you think manufacturers should consult with patients when investigating incidents (you may want to consider: how the manufacturer would find patients with lived experiences, methods of communication, how the manufacturer would demonstrate that they have taken into account patient views).

82.1 says Mfrs must submit reports to MHRA under certain circs. Does that include near misses? Do healthcare professionals report problems directly to the MHRA too?

I don't know if there's value in consulting with patients & public during the *technical* investigation. Possibly their input could be useful in gathering info about how the device is being used in the real world (may differ from expected). That said as 'someone who flies' I'd not expect to be consulted on an aircraft accident investigations - perhaps this analogy only works if the medical device is used BY patients, rather than ON patients by healthcare prof's.

I'd assume consultation would be sensible at the FSN stage, to ensure the info made sense and was unambiguous. As far as I know Patient Information Leaflets are 'road tested' in this way (at least I thought they were!), there's also an entire genre / industry of people ensuring the readability and applicability of patient information.

Finding patients with lived experience
Companies may want to use a third party if they're not allowed to chat directly with the public (I'm thinking about ABPI regulations on pharmaceutical companies, not sure if that applies here). People are pretty easy to find on Twitter / Fb etc though that does open up the possibility of negative publicity if replies are negative. There are charities and patient support groups for almost every possible illness or condition, Google or Charity Commission should uncover them, also healthcare professionals would be able to suggest patients or patient groups. The Association of Medical Research Charities covers a couple of hundred larger medical charities. I think going through healthcare professionals would be a good place to start as there is already a familiar, trusted relationship. Mfrs should reimburse costs.

Methods of communication
Patient comms infrastructure is in place for patient and public involvement in medical research (eg NIHR, Wellcome). The Patient Information Forum (PiF) provides relevant advice, NHS Digital ensure info on the NHS website is language-appropriate and readable at lower literacy levels. There are plenty of science communicators and people working in public engagement with science who could help here too.

Demonstrating patient views considered
Not sure. Paying 3rd party facilitator to find patients, undertake consultation & report patient views might work, as then facilitator could sign off on it (if patients don't wish to be named).

Q82.3 Please provide your reasoning for your answers to questions 82.1-82.2 or any general comments on patient and public engagement during incident investigation.

I think patients harmed during the use of a medical device, and those who might be harmed by its continued use (until investigation produces a solution) should be *invited* to be involved in the investigation, and certainly to have sight of any report before it's submitted. I'm just not sure about how involved they'd want or need to be in technical aspects (eg discussions about software used in a blood glucose meter might not be that relevant to someone with diabetes who's not very familiar with programming, but I think it's helpful for manufacturers to be open and invite patients in).

Presumably usability experts and other designers would also be involved at the investigation stage, as they may have input on improvements to design and also in spotting what might have gone wrong. Probably these types of people are automatically included in a root cause analysis anyway.

The output document from the EPSRC-funded CHI+MED project might be of use too https://chimedblog.wordpress.com/2016/01/29/making-medical-devices-safer-insights-from-the-chimed-project-funded-by-epsrc/.

Here is a list of communities of practice; the focus is on science communication more widely but there are several medical-based groups within it that may be able to offer advice https://scicommjobs.wordpress.com/2021/01/30/scicomm-communities-of-practice/

Both of those links will rather give away who's filling this submission in but I am going to blog my answers so feel free to make this public / no need to redact the links etc.

Q83.1 Do you think that the UK medical devices regulations should include the requirements for manufacturers and health institutions to provide patients with implant information? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q83.2 If you have answered ‘yes’ to question 83.1, is there any other information which should be included within the implant information? If so, please outline below.


Who to contact in case of questions (it may just be "contact your consultant" of course).

Q83.3 Please provide your reasoning for your answers to questions 83.1-83.2 or any general comments on patient implant information.

It sound like patients aren't already getting some info about their implant (which surprises me as I assume everything comes with a patient info leaflet). It might be helpful for these various information sheets to be held centrally by MHRA as packet leaflets are easily lost (and PILs and SPCs are easily findable on the internet).

Q83.4 Do you think the MHRA should introduce a tailored pathway to market approval for: ...

Q83.5 Please provide your reasoning for your answers to question 83.4 or any general comments on possible pathways to approval to bring a device to the UK market.

I don't think I have enough knowledge or information to answer this one. I'm not really sure what a tailored pathway would involve. I'm also not certain about the difference between A and B. It does seem sensible to accept other jurisdictions' approvals (with some checks and balances of course) and not make companies repeat largely similar work for each territory. 

C Innovative Devices seems to have come out of nowhere and I'd assume they could be handled by either A or B, so I'm not sure I've understood this question.




Sunday, 21 November 2021

Open to all but closing 25 November 2021 - Consultation on the future regulation of medical devices in the United Kingdom

Update: I've now submitted my responses to the Chapter 17 (for members of the public) of the consultation and you can read them here.

*******************************

 This is a wide-ranging consultation on medical devices (which includes big serious medical machines that go 'ping' in hospitals as well as contact lenses and spectacles). Everyone is welcome to give input and there's a chapter (chapter 17) specifically for members of the public (though they're also welcome to comment on any or all chapters too). 

The full thing is here: Consultation on the future regulation of medical devices in the United Kingdom



 

 

 

Chapter 9 is about In vitro Medical Diagnostic Devices, eg lateral flow tests
Chapter 10 is about Software as a Medical Device
Chapter 11 is about Implantable Devices, and so on.

(1) You can read Chapter 17 "Questions for members of the general public" as a web page or download it as a PDF.

(2) You can give your views online here.


The Sections for Chapter 17
Note that Chapter 17 begins at Section 76 (as sections 1 - 75 are in earlier chapters) and ends at Section 83.

There are questions for members of the public associated with Sections 78, 79, 80, 82 and 82. Read the section then answer the questions that follow it, using the 'give your views' link in (2) above.

Section 76 - Introduction
- a bit of scene setting, who's behind this consultation and what does it cover

Section 77 - Background Information on Medical Device Regulation
- how medical devices have been approved so far

Section 78 - Scope and classification
- what's included, and what should be included
• Products without a medical purpose
includes 3 questions (Q78.1, Q78.2 & Q78.3)
• Classification
includes 2 questions (Q78.4 & Q78.5)

Section 79 - Economic operators, registration of medical devices and Unique Device Identification
• Health Institutions (inc 3 questions, Q79.1, Q79.2 & Q79.3)
• Importers and Distributors
(inc 2 questions, Q79.4 & Q79.5)
• Unique Device Identification (UDI)
(inc 3 questions, Q79.6, Q79.7 & Q79.8)

Section 80 - Clinical investigations and performance studies

• Clinical investigations of medical devices
(inc 3 Qns, Q80.1, Q80.2 & Q80.3)
• Summary of Safety and Clinical Performance (SSCP)
(inc 3 Qns, Q80.4, Q80.5 & Q80.6)

Section 81 - Approved Bodies and Conformity Assessment
81.1 This section does not contain questions on the above topic in light of its technical nature. To share your thoughts on this topic, see Chapters 5 and 6 of the full consultation.

Section 82 - Post market surveillance, vigilance, and market surveillance
• Vigilance (reporting of incidents)
(inc 3 questions, Q82.1, Q82.2 & Q82.3)

Section 83 - Specific products and topics
• Implantable medical devices
(inc 3 questions, Q83.1, Q83.2 & Q83.3)
• Routes to market
(inc 2 questions, Q83.4 & Q83.5)


The Questions about Chapter 17
The 27 questions are listed below but some contain options to select 'a' or 'b' etc and I've not included those here, please see the web page or PDF linked above.
 

Q78.1 Do you think these products should be regulated under the UK medical devices regulations? (Yes/No/No Opinion/Don’t Know)

Q78.2 If you have answered ‘yes’ to question 78.1, which products should be regulated under the UK medical devices regulations (please select all those which apply) [see list in web page or PDF linked above in (1)]

Q78.3 Please provide your reasoning for your answers to questions 78.1-78.2 or any general comments on key considerations for the regulation of products without a medical purpose.

Q78.4 Do you think the classification rules for general medical devices and IVDs should be amended as above? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)  

Q78.5 Please provide your reasoning for your answer to question 78.4 or any general comments on the classification of medical devices (including ideas for other ways classification may need to change).

Q79.1 Do you think that health institutions should be required to meet certain requirements for ‘in house’ manufactured devices, such as those laid out above? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q79.2 If you have answered ‘yes’ to question 79.1, please choose which requirements should be met by health institutions (select all those which apply from the list below):
[see list in web page or PDF linked above in (1)]

Q79.3 Please provide your reasoning for your answers to questions 79.1 and 79.2, or any general comments on the rules that should apply to ‘in house’ manufacturing of medical devices.

Q79.4 Do you think that medical device importers/distributors should meet additional requirements such as those outlined above? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)  

Q79.5 Please provide your reasoning for your answer to question 79.4 or any general comments on rules applying to importers/distributors of medical devices in the UK

Q79.6 Do you think manufacturer should be required to assign UDI numbers to medical devices before they enter the UK market? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q79.7 What types/classes of medical devices should be included in the requirement for UDI storage (select only one)?
[see list in web page or PDF linked above in (1)]

Q79.8 Please provide your reasoning for your answers to questions 79.6-79.7 or any general comments on UDI requirements for medical devices.

Q80.1 Do you think the UK medical devices regulations should include stricter requirements for claiming equivalence? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q80.2 If yes, should it be the requirements above or other? [multi-choice options of the above requirements plus other – please specify

Q80.3 Please provide your reasoning for your answers to question 80.1 and 80.2 and/or any general comments on rules that you think should apply to claiming equivalence to another medical device as set out above.
 
Q80.4 Do you think the UK medical devices regulations should introduce the requirement for an SSCP for medical devices? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q80.5 What types/classes of medical devices should require a SSCP (select all that apply)?
[see list in web page or PDF linked above in (1)]

Q80.6 Please provide your reasoning for your answers to questions 80.4-80.5 and/or any general comments on introducing a requirement for medical devices to have SSCPs.

Q82.1 Do you think manufacturers should be required to consult with patients when investigating device incidents? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q82.2 If you have answered ‘yes’ to question 82.1, how do you think manufacturers should consult with patients when investigating incidents (you may want to consider: how the manufacturer would find patients with lived experiences, methods of communication, how the manufacturer would demonstrate that they have taken into account patient views).

Q82.3 Please provide your reasoning for your answers to questions 82.1-82.2 or any general comments on patient and public engagement during incident investigation.

Q83.1 Do you think that the UK medical devices regulations should include the requirements for manufacturers and health institutions to provide patients with implant information? (‘Yes’ / ’No’ / ’Don’t Know/No Opinion’)

Q83.2 If you have answered ‘yes’ to question 83.1, is there any other information which should be included within the implant information? If so, please outline below.

Q83.3 Please provide your reasoning for your answers to questions 83.1-83.2 or any general comments on patient implant information.

Q83.4 Do you think the MHRA should introduce a tailored pathway to market approval for:
[see list in web page or PDF linked above in (1)]

Q83.5 Please provide your reasoning for your answers to question 83.4 or any general comments on possible pathways to approval to bring a device to the UK market.




Thursday, 2 November 2017

Seller of GcMAF on trial - 'banned' product, unlikely claims made for it

Some of the people behind Immuno Biotech Ltd are to stand trial later this week for selling products containing GcMAF which has been wrongly touted (papers retracted by the journals that published them) as a cure-all for a number of conditions, including cancer. Despite that this trial does not appear to involve the Cancer Act 1939.

There's no good evidence that GcMAF is of any particular use as a treatment for anything and the fact that it's derived from blood products means particular care would be needed when giving this sort of thing to people.

In 2015 the MHRA (Medicines & Healthcare products Regulatory Agency) shut down a Cambridgeshire factory (UK's MHRA Shuts Down GcMAF Plant, 27 Feb 2015) that had been producing GcMAF (also known as First Immune).  The product itself is unlicensed / unapproved (effectively 'banned') so may not be marketed for anything and the equipment used to produce it may have been contaminated because poor manufacturing processes were in place.

It was also banned from import into Guernsey in Feb 2015 and their health department urged users or former users of GcMAF to contact their GP.

David Noakes, CEO of Immuno Biotech Ltd, is a former Guernsey resident who appeared on The One Show in 2015 talking about GcMAF - the interview did not appear to go well.



He and colleagues* appeared at Southwark Crown Court yesterday before their trial begins on 5 Nov (or possibly in 2018, conflicting reports "All four will stand trial at the same court next year.") - it's expected to take six weeks.

Further reading
*David Noakes - CEO, Brian Hall - associate, Emma Ward - biochemist and Loraine Noakes - distribution firm director and also his ex-wife.

Things to bear in mind
There are several different ways in which an untested alternative "treatment" can cause harm -
1) by containing an ingredient that's harmful, or by being prepared in such a way that means harmful ingredients are present at problematic doses
2) by being utterly harmless but containing nothing of use and offering no real help - wasting time for getting real treatment and wasting money
3) by offering false hope




Sunday, 30 August 2015

Skeptic successes in homeopathy

I've started a collection of activities undertaken by people skeptical of homeopathy and the successes they've had in taking homeopathy to task for its misleading claims. For fairness there's also a segment on failures which I'll update too - we can learn from things going wrong.

I'll also add a section for individual succcesses (eg NHS Lothian's decision to shelve funding for homeopathy was recently challenged legally by a homeopathy enthusiast but this challenge failed) but it's mostly overarching categories at the moment. It feels like there are a few more categories to be added but it's late...

Sunday, 11 May 2014

MHRA criticised Vedanate (aka Vedagrin) for misleading claim about Type 2 diabetes

I missed Vedanate / Vedagrin's moment in the spotlight last year when the MHRA (the UK's Medicines & Healthcare products Regulatory Agency) put out a press release warning people with Type 2 diabetes to avoid the product, and asked the manufacturers to stop selling it.

From what I can gather the product is still on sale (and it seems it can be bought in the UK) as part of the PayDot affiliate marketing scheme, which is part of the larger TwistForum network.

The company's website (1), which I shan't (hyper)link to is http://www.vedanate.com/ and the PayDot info site (3) for affiliate marketers is at http://www.paydot.com/affiliates/directory/health-beauty/nutritional-supplements/vedanate-1095

1. Vedanate website
The picture of the doctor used on the Vedanate website is suspiciously similar to one used on this unrelated Tech website, so I'd have to assume the use of (perfectly legal) stock photos, though it's a shame that the implication is made that the quote next to the man might have been made by him. It's easy to use tools like Google Images to do a reverse-image search on any picture and find this sort of thing out. It's not a big deal but it amused me.
 
Tech-Hunt website
Vedanate website



The website provides a list of ingredients but no information about any evidence that a combination of these is safe or effective in managing blood glucose levels. I was not able to find any evidence of human trials mentioned on their website, not even in their FAQ.




 

More troubling is that the product is advertised on the website as a 'medicine' - and even if it wasn't advertised in that way I think it would be considered as such by the MHRA, which has recently closed its period of grace for herbal medicines:

"...as of 1st May 2014, unlicensed manufactured herbal medicines without a traditional herbal registration (THR) or product licence (PL) can no longer be sold to consumers and must be removed from shelves" - End of herbal sell through period (30 April 2014) MHRA press release


I don't know if Vedanate has the correct license for sale in the UK....

2. MHRA's 2013 announcement about Vedanate
Vedanate appears to be an unlicensed herbal remedy:
"The advertisement for Vedagrin (also known as Vedanate) promotes the unlicensed medicine as an alternative to prescribed diabetes medication with the words “say goodbye to your diabetes medication forever”. This breaks advertising regulations for medicines and the MHRA has instructed the company to stop selling the product."
 - according to the manufacturers the words in italics have since been removed, I don't know if this means that the MHRA has lifted its requirement for them to stop selling it.

Reference: MHRA issues warning to people with diabetes about dangerous herbal food supplement claims (3 July 2013) MHRA Press release

3. PayDot network's website for Vedanate affiliate marketers
Affiliate marketers create websites to highlight the benefits of a particular product and encourage people to buy it. There's a link on their site that refers visitors to the Vedanate website from which they can buy it, and in doing so the affiliate marketer receives a cut of the sales (15% for Vedanate). Presumably the more affiliate websites there are for a product, the greater the chance of someone coming across that product, in this case Vedanate.

PayDot liaises between the makers of Vedanate and the affiliates who refer purchasers to the product website, and they provide information about the product for potential affiliates, for example:
"Why promote Vedanate?
Thanks to our affiliate program webmasters have ability to earn by helping people suffering from type II diabetes. We have all necessary tools for webmasters (text links, wide choice of banners in English and German) to productively work together."

PayDot also have another diabetes product on their market, called Diabain.

I've previously written on the MoreNiche network, which is another TwistForum affiliate network that has a variety of products for sale including Phen375 and the Office of Fair Trading worked with them to make sure that affiliate sites are much clearer that they are taking a small cut of the profits (here's an example discussion on the MoreNiche forum).